Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Admin  
#1 Posted : 07 August 2006 15:54:00(UTC)
Rank: Guest
Admin

Posted By ARB
I have been told by a consultant that Manual Handling Risk assessments don't have to be recorded if:

a) The operation is low risk and easily repeatable/trainable, or;
b) it's more work to record the assessment than carry out the operation.

While I can see the sense in this to cut down on my paperwork, I can't find this written in the MHO Regs or ACoP, and I'm not going to adhere to it until I see it in B&W from the HSE.

Anyone got any ideas where this might stem from, or is it just a bit of wishful thinking?

Al.
Admin  
#2 Posted : 07 August 2006 15:58:00(UTC)
Rank: Guest
Admin

Posted By ITK
It is in the guidance to Regulation 4 of MHOR 1992.

Page 12 to be specific.
Admin  
#3 Posted : 07 August 2006 16:12:00(UTC)
Rank: Guest
Admin

Posted By ARB
ITK,
I've got the ACoP (L23 2004 edition)open in front of me and can't see it on page 12 (Yes I'm wearing my glasses). Is it in a specific paragraph, or am I not interpreting it properly?
Admin  
#4 Posted : 07 August 2006 16:18:00(UTC)
Rank: Guest
Admin

Posted By tommy_t
Page 15 Recording the assessment paragraph 66
Admin  
#5 Posted : 07 August 2006 16:20:00(UTC)
Rank: Guest
Admin

Posted By The toecap
I found it on page 15 at the bottom. Mine are more up to date (as amended). All modern now you know.
Admin  
#6 Posted : 07 August 2006 16:22:00(UTC)
Rank: Guest
Admin

Posted By The toecap
Recording the assessment
66 In general, the significant findings of the assessment should be recorded
and the record kept, readily accessible, as long as it remains relevant. However,
the assessment need not be recorded if:
(a) it could very easily be repeated and explained at any time because it is
simple and obvious; or
(b) the manual handling operations are of low risk, are going to last only a
very short time, and the time taken to record the assessment would be
disproportianate
Admin  
#7 Posted : 07 August 2006 16:25:00(UTC)
Rank: Guest
Admin

Posted By ITK
Ah yes forgot sorry its an old copy I keep in my drawer, the departmental copy is the up to date one. Its on page 15/16.
Admin  
#8 Posted : 07 August 2006 16:27:00(UTC)
Rank: Guest
Admin

Posted By The toecap
Ah well you see. Up there for thinking down there for kicking
Admin  
#9 Posted : 07 August 2006 16:30:00(UTC)
Rank: Guest
Admin

Posted By ARB
Thank you to all! I'm still going to want to see generics from our subbies for the low risk handling, even if only so they can evidence the training given to their staff, and that they understand they need to carry it out.

Most of the handling injuries I find tend to be from minor tasks e.g the office administrator lifting packs of paper - not the site guys lifting tools and bricks. Anyone else find that the support functions get a bit left out?
Admin  
#10 Posted : 07 August 2006 16:38:00(UTC)
Rank: Guest
Admin

Posted By Philip McAleenan
Al,

It’s always worth discussing your concerns with your consultant and asking him/her to clarify any points of doubt. That’s what you pay your fees for. Anyway. here is the specific UK regulation relating to the assessment. No mention to record or not to record in it.

4.—(1) Each employer shall—
(a) …; or

(b) where it is not reasonably practicable to avoid the need for his employees to undertake any manual handling operations at work which involve a risk of their being injured—

(i) make a suitable and sufficient assessment of all such manual handling operations to be undertaken by them, having regard to the factors which are specified in column 1 of Schedule 1 to these Regulations and considering the questions which are specified in the corresponding entry in column 2 of that Schedule,

(ii) …

(2) Any assessment such as is referred to in paragraph (1)(b)(i) of this regulation shall be reviewed by the employer who made it if—

(a) there is reason to suspect that it is no longer valid; or

(b) there has been a significant change in the manual handling operations to which it relates;
and where as a result of any such review changes to an assessment are required, the relevant employer shall make them.

On the other hand, the Management of Health & Safety at work regs. state that significant findings are to be recorded, with the emphasis being on significant,

(6) Where the employer employs five or more employees, he shall record -
(a) the significant findings of the assessment;

Hope this clarifies. Philip
Admin  
#11 Posted : 07 August 2006 17:01:00(UTC)
Rank: Guest
Admin

Posted By warderic
Forget the regulations you need the assessments for insurance purposes. If you have a claim the first thing they will ask for is risk assessments. Its the insurance people that have driven us to risk assess and record every task. With them you cant allow an employee to move without a risk assessment, not forgeting a safe system of work for good measure.
Admin  
#12 Posted : 08 August 2006 07:29:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
Hi ARB

You wrote:
"While I can see the sense in this to cut down on my paperwork, I can't find this written in the MHO Regs or ACoP, and I'm not going to adhere to it until I see it in B&W from the HSE."

and then when getting a response:
"Thank you to all! I'm still going to want to see generics from our subbies for the low risk handling, even if only so they can evidence the training given to their staff, and that they understand they need to carry it out."

This being the case it is not quite clear to me what was wanted. But I would reiterate some earlier advice - if you talk to the Consultant, he/she will talk back!

Admin  
#13 Posted : 08 August 2006 07:35:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
Warderic

"Forget the regulations you need the assessments for insurance purposes"

We all know insurance companies are risk averse, but we all know we have to live in the real world. I would suggest that if you are carrying out RAs purely to satisfy your insurance company then perhaps you need to review the H&S ethos within your company.

Is
Admin  
#14 Posted : 08 August 2006 08:57:00(UTC)
Rank: Guest
Admin

Posted By warderic
Is, I suggest you read my comments more carefully before making such remarks. The fact is insurance companies do drive risk assessments to the extreme. The HSE do not require written risk assessment for every task unless their is a significant risk. The end result is, that we, encouraged by the insurance companies, have created endless paperwork, most of which has no real meaning. Why do you think the HSE have introduced new guidelines on risk assessments?
Admin  
#15 Posted : 08 August 2006 11:19:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
Only if you allow them Warderic.

'A' was told by their insurance company that amongst numerous other requests a 'permit to work' system is required for all contractors working on site. This is a low risk activity company.

Discussed/argued with the insurers and all requests were dropped - why because sufficient systems were already in place and we could show that all 'significant' risks had been looked at. The HSE rationale played a large part in the decision.

Hence the comment about ethos. If your current systems are adequate then the insurers have no choice but to accept them. Or try another insurer.



Admin  
#16 Posted : 08 August 2006 12:11:00(UTC)
Rank: Guest
Admin

Posted By Philip McAleenan
It is often posted on this site that written risk assessments are required where there are significant risks. In reality the regulations require that an employer record the significant findings of an assessment, which is a different matter entirely.

A finding is a conclusion arrived at after examining of the facts of the situation.
For it to be significant it must have an important influence or effect on the proposed activity or operation.

By way of example, an assessment of a work operation that shows all the necessary controls to be in place must conclude, “work operation safe to proceed”.

Alternatively, where essential controls have yet to be identified or implemented the conclusion must be “work operation not safe to proceed”.

Both of these are significant findings, the former permitting the continuation of the work operation, the latter prohibiting it, and by extension requiring that the operative/manager do more before he can give the go-ahead.

It is up to the individual how much more they wish to write into their record of findings, but it would be preferable if time and energy were devoted to developing and implementing the necessary control mechanisms, and writing safe working procedures if these are required than writing volumes of risk assessments.

Note too that the requirement is to make finding of fact. This negates the necessity of preparing one of the many elaborate risk matrices that preponderate, as these are neither facts nor a means of determining the significance of a finding of fact.

Regards, Philip
Admin  
#17 Posted : 08 August 2006 12:29:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
But in the Guidance under Suitable and sufficient:

... insignificant risks can usually be ignored, ac can risks arising from routine activities associated with life in general........

The reference to risk matrices appears to be off topic but if you would like to start another thread?
Admin  
#18 Posted : 08 August 2006 12:36:00(UTC)
Rank: Guest
Admin

Posted By warderic
Is, as expected you are firing from the hip again. Our ethos is much the same as others. We carry out risk assessments in the interest of reducing risk to our employees. We carry out risk assessments over and above because when a claim comes in the insurance company will ask for the risk assessments for everthing including passing wind. If you dont have them, in most cases you will be writting a cheque. Yes you can argue before an event as you did, but arguing after the event is a different matter.
Admin  
#19 Posted : 08 August 2006 13:45:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
"We carry out risk assessments over and above because when a claim comes in the insurance company will ask for the risk assessments for everthing including passing wind. If you dont have them, in most cases you will be writting a cheque."

That isn't really the case, and I'm sure you know it. If you can show me some examples of writing a cheque solely because you haven't got an appropriate risk assessment, then I'll be happy to review what I've said so far.

I'd prefer a discussion without the the 'twitchy' comments if possible.
Admin  
#20 Posted : 08 August 2006 13:56:00(UTC)
Rank: Guest
Admin

Posted By ARB
I didn't think it would stir up this much interest.

I was originally told this piece of info. from one of my sub-contractor's consultants. His thread was along the line of " We don't have to give you manual handling risk assessments because......". Bearing in mind that this is a construction company, I have seen them carry out manual handling tasks with significant risks attached.

Not wishing to tar all of the good consultants out there, but I don't believe everything consultants tell me, as I've been given poor / totally incorrect advice in the past.

ARB

Admin  
#21 Posted : 08 August 2006 14:49:00(UTC)
Rank: Guest
Admin

Posted By Rob Tuttey
Lots of talk about insurance and claims - what about proof in the event of enforcement action. It's very difficult to prove you have completed an assessment or even concidered an activity as low risk after someone has been injured (HSAWA - reg 40 or 41 I think from memory). With many MH injuries resulting in over 3 days for various reasons, I've found its always worth listing all activities then stating which are low risk and which require a full assessment (sort of Matrix header sheet). This has helped with both claims and enforcement action in a previous role. Just a thought, not looking to enter the debate further. I personally find the arguments unhelpful for others trying to seek clarification.
Admin  
#22 Posted : 08 August 2006 14:56:00(UTC)
Rank: Guest
Admin

Posted By Is Kismet
The HSE also suggest this in their Manual Handling RA form/template for manual handling - if it is low risk then you don't complete the full form.

Admin  
#23 Posted : 08 August 2006 15:09:00(UTC)
Rank: Guest
Admin

Posted By Darren J Fraser
I would like to point out that the original question was to do with advise from a consultant, and their statement that a risk assessment does nothave to be recorded if:

a) The operation is low risk and easily repeatable/trainable, or;
b) it's more work to record the assessment than carry out the operation.

ARB was seeking clarification, which The Toecap provided in their response on Mon 07.08.06 @ 16.22.

If in doubt, do / request assessment or have copy of ACoP/Guidance avaliable with page marked to show all interested parties.
Admin  
#24 Posted : 08 August 2006 17:51:00(UTC)
Rank: Guest
Admin

Posted By Chris Pope
I have found insurers willing to listen to informed decision making, so that genuine risks can be addressed. Don't get bogged down, into doing things you just don't believe will reduce danger.
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.